TRINIDAD GAMBOA-ROCES vs. JUDGE RANHEL A.
day period and offered his deepest apologies, explaining that
PEREZ
A.M. No. MTJ-16-1887; January 9, 2017
FACTS: Trinidad Gamboa-Roces filed an administrative
complaint against Judge Ranhel A. Perez charging the latter
with gross ignorance of the law for his failure to render
judgment on the consolidated ejectment cases within the
reglementary period as prescribed by law.
In her complaint, complainant claimed that she was one of
the plaintiffs of an unlawful detainer cases. After the
mediation proceedings and the Judicial Dispute Resolution
proceedings failed, it was referred back to the MCTC for trial
and was set for preliminary conference. As a new judge was
soon to be assigned in the MCTC, the preliminary conference
was reset, by Judge Evelyn D. Arsenio, the then acting
Presiding Judge.
Complainant stated that when Judge Perez was appointed
and assumed office, her counsel filed two (2) separate
motions for his inhibition in the two cases on the ground that
she was previously involved in a legal confrontation with
Judge Perez himself when he was representing his parents.
Her motions, however, were denied in separate orders.
Thereafter, Civil Case Nos. 451- M and 452-M were
consolidated in the Order, dated March 11, 2014. After the
preliminary conference for the two cases was held, the
parties were then required to file their respective position
papers. Thereafter, Judge Perez issued the Order, dated
November 21, 2014, submitting the cases for resolution. With
this, complainant claimed that despite the lapse of more than
ten (10) months, Judge Perez failed to decide the cases in
violation of the 30-day reglementary period within which to
decide an ejectment case.
Judge Perez on the other hand, admitted that Civil Case Nos.
451-M and 452-M were decided beyond the prescribed 30-
required period constitutes gross inefficiency. Moreover,
the delay was inadvertent and not intended to prejudice the
plaintiffs. He explained that he was able to finish the final
draft of his decision on December 1, 2014, but in his desire
to have "a perfect decision," he did not immediately forward
the draft to his Clerk of Court as he would still polish its
decision. He, however, got distracted with other issues and
matters in the office.
The Office of the Court Administrator (OCA) through its
Report, dated September 7, 2016, recommended that the
complaint be re-docketed as a regular administrative matter
and that "Judge Perez be found GUILTY of undue delay in
rendering a decision or order and be admonished to be more
mindful in the performance of his duties particularly in the
prompt disposition of cases pending and/or submitted for
decision/resolution before his court.
Issue:
Whether or not the Respondent as the Presiding Judge is
guilty of undue delay of rendering a decision within the
reglementary period as prescribed by law.
Ruling:
Yes, the Respondent as the Presiding Judge is guilty of undue
delay of rendering a decision within the reglementary period
as prescribed by law..The Supreme Court cited Section 15,
Article VIII of the 1987 Constitution which requires the lower
courts to decide or resolve cases or matters for decision or
final resolution within three (3) months from date of
submission. In complaints for forcible entry and unlawful
detainer as in this case, Section 10 of the Rules on Summary
Procedure specifically requires that the complaint be resolved
within thirty (30) days from receipt of the last affidavits and
position papers. Without any order of extension granted by
this Court, failure to decide even a single case within the
Sections 2 and 5 of Canon 6 of the New Code of Judicial
Conduct enjoin the judges to devote their professional
activity to judicial duties and to perform them, including the
delivery of reserved decisions, efficiently, fairly, and with
reasonable promptness. This obligation to render decision
promptly is further emphasized in Administrative Circular No.
3-99 which reminds all judges to meticulously observe the
periods prescribed by the Constitution for deciding cases
because failure to comply with the prescribed period
transgresses the parties' constitutional right to speedy
disposition of their cases.
The Court has always reminded the judges to attend
promptly to the business of the court and to decide cases
within the required periods for the honor and integrity of the
Judiciary is measured not only by the fairness and
correctness of the decisions rendered, but also by the
efficiency with which disputes are resolved. Any delay in the
disposition of cases erodes the public's faith and confidence
in the Judiciary. Thus, judges should give full dedication to
their primary and fundamental task of administering justice
efficiently, in order to restore and maintain the people's
confidence in the courts.
The explanation given by Judge Perez of his being
inexperienced as a newly appointed judge was too flimsy.
The excuses only show his lack of diligence in discharging
administrative responsibilities and professional competence in
court management wherein a judge is expected to keep his
own listing of cases and to note therein the status of each
case so that they may be acted upon accordingly and without
delay and must adopt a system of record management and
organize his docket in order to monitor the flow of cases for a
prompt and effective dispatch of business.